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## Chapter **12 Recordkeeping and Reporting**  **Contents** 12.1 General
................................ ................................ ................................ ................................ . 2 12.2 Notifications
................................ ................................ ................................ ......................... 3 12.3 Recordkeeping
................................ ................................ ................................ ..................... 3 12.4 Electronic Reporting
................................ ................................ ................................ ............ 6 Compliance with Part 75 Reporting
................................ ................................ ........................ 6 New Reporting to ECMPS
................................ ................................ ................................ ...... 7 Duplicative Reporting
................................ ................................ ................................ ............. 812
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### 12.1 **GENERAL Comment 12.1**  **- 1:**  Commenter 9664 asked that the reporting and recordkeeping provisions be changed. The commenter requested that the EPA change 60.46Da (h) and 60.46Da (i) be updated to include the following language, "any EGU meeting the standard through long
- term containment in a subsurface geological formation (either through geologic sequestration or in enhanced oil recovery) [must] provide documentation showing that the volume of captured CO 2 necessary to achieve the standard has been injected onsite to a facility permitted under the UIC program and reporting under Subpart RR [of Part 98], or transferred to a facility that is permitted under the UIC program and reports under Subpart RR." The commenter also asked that the reporting become a condition of the title V permit for the facility . 42 USC section 7661c(a). **Response 12.1 -**  **1:** As explained in section III.B of the final rule preamble, the EPA is combining the steam generator and combustion turbine categories into a single category of fossil fuel
- fired electricity generating units for purposes of promulgating standards of performance for GHG emissions. The standards of performance for CO 2 emissions will be codified in a new 40 CFR part 60, subpart TTTT. The EPA is not finalizing the co
- proposed approach of codifying the standards of perfo rmance in the 40 CFR part 60, subparts Da and KKKK. Although the comment regards requested revisions to 40 CFR part 60, subpart Da provisions, a response to the substance of the comment in terms of subpart TTTT is provided. See Chapter 6 of this document f or response s relating to 40 CFR Part 98 Subpart RR. See preamble section XII. Implications for PSD and Title V Programs for further discus sion on PSD and Title V permits
. **Comment 12.1 -**  **2:** Comment 2: Commenter 8952 asked that the recordkeeping and reporting provisions be ch anged. The commenter recommended a few revisions to the recordkeeping and reporting requirements:

 change hourl y fuel consumption rates to monthly fuel consumption  change hourl y generation data to monthly generation data The commenter stated that the EPA c ould "gather these data directly without imposing an additional regulatory

burden on facilities." The commenter noted that substantial amounts of these data are available through the EIA Electric Power Monthly
. **Response 12.1 -**  **2:** The final rule does not require records of ho url y fuel consumption or hourly generation to be kept as separate entities
. However, for sources using Appendices D and G of Part 75 to demonstrate compliance, the quarterl y Part 75 electronic emissions reports do require hourly fuel flow rates to be repor ted
. And for all affected units, gross hourly electrical load is reported in the quarterl y Part 75 electronic emissions data reports (EDRs).12
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**Comment 12.1 -**  **3:** Commenter 9427 asked "when do notification, recordkeeping, monitoring, and reporting requirements begin to appl y? " The commenter recommended the following language, "Notifications, recordkeeping, monitoring, and periodic reporting requirements would be the responsibility

of new stationary

combustion turbine owners/operator that meet the 'three consecutive calendar year s' applicability criteria." **Response 12.1 -**  **3:** In view of the changes to the applicability section of the rule, there is no need to provide an y notices of applicability
. Initial applicability is based solel y on the design heat input capacity of the unit and the size of the e lectrical generator, and once a unit is identified as “affected”, it remains in the program
. Other notifications (i.e., the commencement of construction and unit startup notices in §60.7(a) and the applicable notifications in §75.61 shall be submitted with in the time frames specified in those sections. 

### 12.2 **NOTIFICATIONS Comment 12.2**  **- 1:**  Two commenters (9425 and 9666) supported the notifications required b y the rulemaking. **Response 12.2 -**  **1:** The EPA acknowledges the commenters’ support. **Comment 12.2 -**  **2:** Two commenters (9425 and 9666) noted some duplicative notifications. Commenters 9425 and 9666 stated, "EPA should exempt the notices in Section 75.61 from the duplicate reporting requirements in Section 60.4, which requires that all 'request, reports, applications, submittals, and other communications to the Administrator' be submitted 'in duplicate' to the appropriate EPA Regional Office and to any delegated state." Commenter 9666 noted that "section 75.61 already requires submission to those officials, there is no basis for requiring additional reporting 'in duplicate' under Part 60." **Response 12.2 -**  **2:** Table 3 of the final rule clarifies that the notices under §75.61 are not subject to the submittal requirements of §60.4, and that duplicate submittals are not required for information that is subject to those requirements
. 

### 12.3 **RECORDKEEPING Comment 12.3**  **- 1:**  Commenter 9426 asked that the EPA specify what "maintaining records of calculations" means. The commenter wanted assurance that the EPA did not expect "sources to manually calculate all averages used for compliance with these rules, and then maintain hard copies of those calculations." The commenter asked that the EPA modify the rule so that "the rule is clear that computerized database records and calculations, with reporting verifications of equations such as required under 40 CFR Part 75, are acceptable." **Response 12.3 -**  **1:** The EPA agrees with the commenter. The final rule specifies that computerized (electronic) records are acceptable as long as they can be made readil y available to inspectors and auditors upon request.12
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**Comment 12.3 -**  **2:** Commenters 9426 and 10023 commented on duplicative recordkeeping requirements. The commenters asked that the EPA "not impose any additional recordkeeping requirements that either duplicate Part 75 or go beyond what is required for Part 75." **Response 12.3 -**  **2:** The final rule does not require any duplicative recordkeeping between Parts 60 and 75
. However, there are certain records that must be kept for the purposes of the NSPS (e.g., records of the calculations used for the compliance determinations), which are not required under Part 75. **Comment 12.3 -**  **3:** Several commenters (9426, 9514, 9666, and 10023) offered recommendations related to electronic compliance records. One commenter (9426) asked that the EPA modify the language in paragraphs 60.46Da (i)(8) and 60.4391(h)(3) so that it is clear that electronic records are acceptable fo r the initial two years. Three c ommenters ( 9426, 9666, and 10023 ) asked for clarification on the term s "onsite" and "offsite" when related to recordkeeping. Commenter 9426 asked that the language be modified to indicate that electronic records can "be stored at an offsite location for the first two years as long as they are readil y accessible onsite , " while c ommenters 9666 and 10023 stated that "as long as the facility can access the information onsite, there is no reason for it to be phy sically located the re." Commenter 9514 stated that "EPA has not identified any particular (or even generalized) basis for its proposal to permit offsite storage after two years." The commenter asked that the EPA adopt additional language covering record retention. The commenter stated, "For example, under the subpart 98 reporting program for GHGs, records may be stored off site only

' if the records are readil y available for expeditious inspection and review.' 40 C.F.R. Section 98.3(g). In addition, for any records stored elec tronicall y, 'the equipment or software necessary to read the records shall be made available, or, if requested by EPA, electronic records shall be converted to paper documents.' Id." Commenter 9514 asked for clarification on the term "readily available." The commenter suggested "available on demand, not just to EPA, but to state and local authorities, irrespective of jurisdiction over the site where the records are stored, and to the general public." **Response 12.3 -**  **3:** As explained in section III.B of the final rule preamble , the EPA is combining the steam generator and combustion turbine categories into a single category of fossil fuel
- fired electricity generating units for purposes of promulgating standards of performance for GHG emissions. The standards of performance for CO 2 emissions will be codified in a new 40 CFR part 60, subpart TTTT. The EPA is not finalizing the co
- proposed approach of codifying the standards of performance in the 40 CFR part 60, subparts Da and KKKK. Although the comment refers to 40 CFR part 60, s ubpart Da provisions, a response to the substance of the comment in terms of subpart TTTT is provided. The final rule requires that records be maintained for 3 years after the date of each occurrence, measurement, maintenance, corrective action, report or record. The final rule clarifies that each record must be kept on site or be accessible from a central location by

computer or other means that instantly provide access at the site for at least 2 years after the date of each recorded action and may be kept off site for the remaining ye ar(s).12
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**Comment 12.3 -**  **4:** Commenter s 9666 and 10023 noted places in the proposed rule that contain unnecessary

or duplicative recordkeeping provisions. Commenters 9666 and 10023 noted that the provisions in 60.7(b), 60.7(f), 60.5560(a), 60.4391( a) referring to startups and shutdowns have no basis to require records of those periods because there are no provisions in the NSPS that apply onl y to startup or shutdown. Commenter 9666 also opposed any recordkeeping requirements that are duplicative of P art 75, spec ifying60.5560(b)
- (d), 60.46 Da (i) ( 1), and 60.4391(b) . This commenter (9666) asked that the EPA remove all recordkeeping provisions that refer to operating months because the compliance period is not monthly
. **Response 12.3 -**  **4:** The final rule does not require any duplicative recordkeeping between Parts 60 and 75
. However, there are certain records that must be kept for the purposes of the NSPS (e.g., records of the calculations used for the compliance determinations), which are not required under Part 75
. The monthly recordkeeping requirements have been removed; rather, records must be kept for each “compliance period”. The final rule does not require records of startup and shutdown to be kept
. The quarterly Part 75 electronic emissions reports show only hours in which the unit operated (combusted fuel)
. Unit startups and shutdowns are easil y identified from the date and time stamps on the operating hours
. **Comment 12.3 -**  **5:** Commenter 9666 disagreed with the EPA's "5 ye ar record retention period for all of the supporting informatio n for the 12
- operating
- month rolling average standard, unless EPA can show a special need as required under the Paperwork Reduction Act regulations." The commenter recommended a 3
- year record retention requirement to match part 75. **Response 12.3 -**  **5:** The EPA agrees that rec ords should be maintained for 3 years after the date of each occurrence, measurement, maintenance, corrective action, report or record, and has revised the final rule accordingl y. **Comment 12.3 -**  **6:** Commenter 8957 asked that the EPA require the owner or operator to keep reco rds that verify

its applicability

status. The commenter stated, "If the owner or operator considers themselves to be subject, they should keep all records and submit all reports as required b y the rule on an annual basis. If the owner or operator does not consider themselves to be affected b y the rule, they should onl y be required to keep records that verify that they are not subject to the rule. A reporting requirement for non
- affected sources should not be required; records should be maintained for five years and reported to EPA or the permitting agency upon request." **Response 12.3 -**  **6:** In view of the changes to the applicability section of the rule, there is no need to provide an y notices of applicability
. Initial applicability is based solel y on the design heat input capac ity

of the unit and the size of the electrical generator, and once a unit is identified as “affected”, it remains in the program
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### 12.4 **ELECTRONIC REPORTING Compliance with Part 75 Reporting**  **Comment 12.4 -**  **1:** Two commenters (9425 and 9666) recommended changes to the reporting l anguage. Commenter 9425 noted that many combined cycle sy stems share a single turbine generator with two or more combustion turbines. The commenter suggested the following text be included in Section 60.4374(a)(3)(i): "The steam turbine output should be accounted for using one of the methods allowed in the Part 75 Policy Manual, Section 17.2 Unit Load Reporting: (1 ) For a combined

- cycle unit (with or without auxiliary firing), if a single generator serves the CT and HRSG, report the electrical outputs (m egawatts) from this generator. (2 ) For a combined

- cycle unit (with or without auxiliary firing), if separate generators serve the CT and HRSG add the electrical outputs (megawatts) from these generators. (3 ) If the HRSG of two or more combined cycle units (CCUs) share a common steam turbine, then, for each CCU, add the electrical output (megawatts) from the generator that serves the CT to an apportioned fraction of the electrical output from the shared steam turbine. Apportion the combined electrical load f rom the common steam turbine to the individual CCUs according to the fraction of the total steam load contributed by each unit. Alternatively, if the turbines are identical, you may apportion the combined electrical load from the common steam turbine to th e individual CCUs according to the fraction of the total heat input contributed by each unit." Commenter 9666 noted that requiring compliance with "'all applicable reporting requirements in Part 75" in 60.5555(c), 60.46Da(h)(4), and 60.4376(d) is overl y broad. The commenter suggested that the EPA "reword this provision to explain that 'applicable reporting requirements' means reporting of information needed to calculate lbs CO 2 /MWh
- i.e., hourly load and any information used to calculate CO 2 mass emissions ." Commenter 9666 also noted that all of the data needed to calculate compliance already are recorded and reported under Part 75 and there is no reason to separatel y require an y reporting under this NSPS until the calendar quarter that contains the end of the month that corresponds to the end of the first compliance period. **Response 12.4 -**  **1:** The final rule incorporates the Commenter 9425’s suggestion to allow the electrical output of a common steam turbine to be apportioned to the individual EGUs according to fraction of the total steam load or (if the units are identical) based on the fraction of the total heat input to the EGUs. The Agency

has also incorporated Commenter 9 666 ’s recommendation to make the Part 75 reporting requirements more specific, i.e., that 'applicable reporting requirements' means reporting of information needed to calculate the CO 2 mass emissions.12
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EPA agrees with Commenter 9666 that the first submission of a quarterl y compliance reports should not be required until the initial 12
- operating month compliance period has been completed
. The final rule makes this clear. **New Reporting to ECMPS Comment 12.4**  **- 2:**  Commenter 9425 asked that "EPA simply require reporting under Part 75. The reference to ECMPS is unnecessary and inappropriate." **Response 12.4 -**  **2:** The EPA disagrees with the commenter an d believes it is necessary to call out ECMPS as the reporting mechanism in the regulation. **Comment 12.4 -**  **3:** Commenter 9666 "does not object to reporting once a ye ar the facility's gross electric output sold to an electric grid during the year, and the potential electric output of the facility ." **Response 12.4 -**  **3:** The EPA thanks the commenter for their comment. **Comment 12.4 -**  **4:** Commenters 9425 and 9666 asked that the EPA specify that the rule determines reporting requirements, not ECMPS. Commenter 9425 noted that the EPA referred to "other information" and "other modifications" that are not clearl y specified. Commenter 9666 "would object to any attempt by EPA to use ECMPS to require reporting of any information, codes, calculations, or other information that is not identified both in the rule and in an ICR approved b y OMB." **Response 12.4 -**  **4:** The EPA disagrees with the commenter and the reporting instructions contains “codes” and other instructions that are necessary to allow data to be submitted in a consistent manner for data elements that are required b y the rule. **Comment 12.4 -**  **5:** Commenters 9425 and 9666 commented on aspects of ECMPS that require clarification. Specificall y, Commenter 9425 noted that CO 2 data in ECMPS are reported hourly but the rule has a different compliance period. Additionally , commenter 9666 asked that the EPA specify

reporting of CO 2 in lb/MWh rounded to the nearest whole number consistent with ASTM rounding conventions and objected to the use of electronic auditing software within ECMPS to "impose on reporting facilities any requirements or quality assurance criteria th at are not identified in the rule." **Response 12.4 -**  **5:** The final rule specifies hourly reporting of CO 2 consistent with 40 CFR part 75 and the EPA has expanded upon the requirements of reporting as it relates to both the rule and part 75 reporting. Compliance will be determ ined on a 12
- operating month rolling average basis which is calculated using all of the hourl y data reported to ECMPS. Additionally, ECMPS does not impose “additional” QA/QC requirements but will provide electronic verification to ensure that data reporte d are consistent with the reporting requirements of the rule.12
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**Comment 12.4 -**  **6:** Commenter 9666 noted that § 72.21(b)(2) requires that each submission under Part 75 be certified b y the facility's DR , however this is not defined under Part 60. The commenter recommended that E PA modify ECMPS to allow certification for Part 60 data b y the owner or operator instead of the DR as defined in Part 75. **Response 12.4 -**  **6:** The final rule requires the DR under 72.2 to make the submissions and the EPA believes the final rule clarifies the commenters concer n. **Duplicative Reporting Comment 12.4**  **- 7:**  Commenters 9425 and 9666 asked that the EPA avoid duplicative reporting in the rule. Commenter 9425 asked for exemptions from part 60 QA/QC for sources using CEMS and to exempt ECMPS reports from the duplicate reporting requirement s in § 60.4. Additionally , Commenter 9666 asked to exempt Subparts Da and KKKK from § 60.7(c) and exempt all electronic reporting requirements from § 60.4. **Response 12.4 -**  **7:** The EPA is removing the requirement for any reporting under 60.4 that would be in duplicate to information that is reported electronically through ECMPS. **Comment 12.4 -**  **8:** One commenter (9426) stated that reporting CH4 and N2O emissions under the NSPS would be duplicative with the GHGRP. **Response 12.4 -**  **8:** This rule does not require reporting of CH 4 and N 2 O emissions.